OPBAS Reports Stronger AML Oversight but Questions Whether Enforcement Goes Far Enough

Key Takeaways

• Supervisory Standards Have Improved Since 2018: OPBAS reports that Professional Body Supervisors are more effective today than at any time since the oversight body was established.
• Enforcement Remains Uneven: Some supervisors still fall short in their enforcement approach, raising concerns about whether sanctions are strong enough to deter non-compliance.
• Structural Conflict Identified: OPBAS reiterates concerns that the dual role of some supervisors as both membership bodies and regulators may hinder robust disciplinary action.
• First Enforcement Action Signals Shift: OPBAS took its first enforcement action against a Professional Body Supervisor last year for failing to meet obligations under the Money Laundering Regulations.
• FCA to Assume Direct Supervision: The UK Government decided in 2025 that the Financial Conduct Authority will take over AML and CTF supervision of the legal and accountancy sectors to simplify oversight and improve consistency.

Deep Dive

The UK’s anti-money laundering oversight regime for lawyers and accountants is stronger than it was in 2018. But according to the latest report from the Office for Professional Body Anti-Money Laundering Supervision, it is not yet where it needs to be.

The report offers a balanced assessment of Professional Body Supervisors (PBSs), the organizations responsible for overseeing AML compliance across the legal and accountancy sectors. OPBAS concludes that supervision is more effective than at any point since it was established, and that PBSs generally demonstrate good levels of compliance.

Yet one concern cuts through the report with clarity: enforcement still does not consistently carry enough weight to deter firms from falling short of minimum standards.

OPBAS points to uneven performance across PBSs, particularly in their enforcement approach. While supervisory frameworks have matured, some bodies continue to underperform when it comes to taking firm action. In parallel, OPBAS suggests that supervision itself could be strengthened in certain areas.

A longstanding structural tension remains part of the story. Some PBSs operate in a dual capacity, both as membership organisations and as statutory supervisors. OPBAS warns that this arrangement can, in practice, hinder effective enforcement, particularly where disciplinary action against member firms is required.

“Fighting financial crime is a priority for the FCA. In recent years, OPBAS has driven progress in the way money laundering is tackled in the legal and accountancy sectors, but improvements are still required,” said Mark Francis, Director of Specialists at the Financial Conduct Authority.

OPBAS, which is housed within the FCA, oversees 25 PBSs charged with preventing financial crime within professional services. Since its founding in 2018, it has expanded its toolkit to push for higher standards and greater consistency.

That toolkit now includes enforcement. Last year, OPBAS took its first formal enforcement action against a PBS that failed to meet its obligations under the Money Laundering Regulations, a notable development in the evolution of oversight of supervisors themselves.

The report also lands amid structural reform. In 2025, the UK Government decided that the FCA will assume direct AML and counter-terrorist financing supervision in the accountancy and legal sectors. The move is intended to simplify the supervisory framework, deliver more consistent oversight, and strengthen efforts to identify and disrupt financial crime.

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